The Interim Aviation Council's Aviation Action Plan marks a significant strategic pivot for the New Zealand aviation sector, which is vital to the country’s economic prosperity and global connectivity. It follows the Ministry of Transport’s Air Navigation System Review from May 2023, which highlighted the need for change and collective action to make it possible. The plan provides the much needed policy intent to reorient the sector and position it better to address systemic challenges and disruptive global forces, safely. 

The plan's strategic framework is built upon a series of shorter-term, initial actions with assigned leadership across government agencies, industry, and the Aviation Council (interim, for the time being) itself. Government-led actions are intended to unlock regulatory barriers and address information gaps, with success contingent on collaboration between public and private sector entities. The plan outlines four core priorities: a world-class regulatory environment, an industry to attract, train, and maintain a skilled workforce, a resilient and productive aviation system, and well-planned infrastructure.

The plan provides much needed direction and, for the first time, a coordinated programme to address the sector’s critical deficiencies. Its strength lies in its clear executive intent, but its success will depend on turning high level ambitions into substantive and properly resourced action.

Aviation rests on a simple discipline: aviate, navigate, communicate. It is about control, direction, and communication, in that order. These qualities are essential in the cockpit, and they should also underpin strategic planning for the sector. The action plan leans heavily on frameworks for future work. What is now needed alongside that is control, through measures that can be executed, clarity about the path forward across all four priorities, and communication that gives the industry confidence in how and when outcomes will be delivered.

A world-class regulatory environment

Regulatory reform is arguably the plan’s most critical pillar, directly addressing widespread industry criticism that red tape and thus “a slow system”, is the primary constraint holding aviation back and making New Zealand a less attractive host for aerospace innovation. This must end. The vision for a world-class, nimble, risk-based, enabling framework is a welcome response to long-standing calls for change.

The government intends to deliver this by reworking civil aviation rules under the Civil Aviation Act 2023 and launching a two-year rolling rule-making programme to implement recommendations of the International Civil Aviation Organisation (ICAO), within the next three months, an ambitious (and  perhaps unrealistic?) timeline. Speed and quality are essential – let’s hope the latter is not sacrificed for the former. 

Regardless of how well designed the framework may be, its success depends on an agile and well resourced Civil Aviation Authority (CAA). That capacity is now under review and must be considered in the context of recent budget reductions across government agencies. Without that commitment, the ambition for a more responsive and enabling system will be difficult to realise.
Regulation alone will not determine the sector’s future. The effectiveness of any framework ultimately depends on the people who bring it to life.

The Human Factor

A world-class aviation system, no matter how technologically advanced, is only as strong as the people who operate it. The Action Plan rightly identifies human capability as the most significant long-term risk to the sector, highlighting a critical vulnerability in its workforce pipeline. The statistics are stark: with a five-year attrition rate of 78% for new entrants, the system is failing to retain the talent it develops. The plan’s proposed actions, such as updating pilot qualifications and developing a future “workforce package of options”, are necessary steps towards addressing this leakage.

However, a successful workforce strategy must stand on three pillars: train, attract, and retain. The plan’s focus is almost exclusively on training and retaining. It is silent on a crucial third pillar: a proactive strategy to attract top-tier overseas talent. The single action to progress mutual recognition agreements for licences is a passive administrative step, not a competitive strategy to draw the world’s best to New Zealand. In a global market where New Zealand is losing talent to better opportunities abroad, our mountains and ranges are not a sufficient drawcard; talent follows opportunity, which requires competitive pay and an innovative environment in which to grow.

A critical component of strengthening the domestic talent pipeline is broadening the pool from which it can draw. The plan’s ambition to increase the participation of Māori and women is a crucial goal. However, achieving this requires a strategy that goes beyond simple recruitment targets. It necessitates a focus on creating equitable access to training and career pathways. This may require targeted financial and social support to overcome existing barriers, ensuring that talented individuals from all backgrounds are equipped to develop and demonstrate their capabilities. The ultimate objective is to create a true meritocracy, where the sector benefits from the widest possible pool of excellence because every potential candidate has had a fair opportunity to earn their place.

Systemic resilience and connectivity

The Action Plan approaches the sector’s economic health with a dual strategy: immediate intervention to stabilise acute symptoms such as rising costs, post-COVID supply chain pressures, and persistent fragility in regional connectivity, and a longer-term diagnosis of the system’s underlying vulnerabilities. 

The immediate interventions are pragmatic. The Regional Infrastructure Fund will support vulnerable regional airlines until 2026, providing a lifeline for essential operational costs and enabling the IT systems needed for efficient network integration. Alongside this, the plan initiates a sector-wide diagnostic phase, with actions to document costs and develop a framework to monitor the system’s health. These are necessary steps toward evidence-based policy.

However, the core of any sustainable solution, the system-wide funding review by the CAA and a review of Airways’ pricing framework, will not be completed until late 2027. The long-term resilience of regional connectivity will ultimately depend on the delivery of a decisive and coordinated funding strategy from the 2027 reviews, without a damaging lapse in support.

Building for climate resilience

Reducing fossil fuel use and transitioning to clean energy are non-priority policy ambitions included in the Action Plan, consistent with the national target of net zero carbon emissions by 2050. Strategic policy support for international efforts to adopt sustainable aviation fuels, introduce more efficient aircraft, and invest in new propulsion and digital technologies provide pathways for emissions reduction and economic growth. 

The Action Plan affirms New Zealand’s alignment with international goals, including ICAO’s net zero target for 2050 and the interim goal of reducing international aviation emissions by five percent by 2030. Participation in ICAO’s Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) will continue, alongside engagement in international forums responsible for negotiating aviation emission targets and regional dialogues on sustainable aviation fuel supply.

Initial steps set out in the plan focus on collaboration and sector engagement. These include the commencement of a Climate and Finance dialogue to advance regional cooperation on sustainable aviation fuel, industry participation in the development of a regional SAF strategy, and reaffirmation of New Zealand’s voluntary participation in CORSIA at the 2025 ICAO General Assembly.

In this domain, the Action Plan prioritises alignment and engagement over early regulatory or investment commitments. The strategy sets the direction for future action but reserves substantive domestic policy and investment decisions for further development.

Other policy ambitions

Beyond the core priorities, the Action Plan is built on several other ambitions intended to support the overall health and integrity of the aviation sector:

• Maintaining high standards of safety and security, embedding a best-practice culture throughout the sector;
• Ensuring New Zealand's participation in the international aviation system is strategic and pursues growth that is in the national interest;
• Improving the passenger experience, with a focus on ensuring disabled people have accessible and efficient air travel services and that all consumers are treated fairly when flights are disrupted; and 
• Creating long-term opportunities for communities, iwi, and businesses to participate and invest in the aviation sector.

Looking ahead

The Aviation Action Plan 2025 represents a necessary and overdue strategic reset for New Zealand's aviation sector. Its primary value lies in providing clear executive intent and a coordinated framework for addressing long-standing, systemic issues that were clearly articulated in the 2023 Air Navigation System Review. For the first time, the industry has a clear direction of travel.

However, the plan is largely a framework of intent. Across regulation, workforce, and infrastructure, it relies heavily on future reviews, the development of options, and funding decisions that are yet to be made. The establishment of a permanent Aviation Council is the critical next step, as the effectiveness of this new body in driving execution will be the ultimate measure of the plan's success. The direction is now set; the challenge will be in the delivery. The sector will be watching closely to see if the commitment to action matches the policy ambitions.

This article is co-written by Gerard Dale (Partner) and Güneş Haksever (Senior Associate) in our corporate and commercial team.